Effective: December 1, 2022
OVERVIEW
PERSONAL DATA WE COLLECT
How We Use Your Personal Data
How We Obtain Your Personal Data
Who We Share Your Personal Data With
YOUR RIGHTS REGARDING PERSONAL DATA
Accessing, Modifying, Rectifying, and Correcting Collected Personal Data
Your California Privacy Rights
Your Nevada Rights
YOUR CHOICES
Communications Opt-Out
Location Information
Cookies, Web Tracking, and Advertising
PROTECTING PERSONAL DATA
OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES
Collection of Personal Data from Children
Third-Party Websites and Services
Business Transfer
Payment Information
Do Not Track
International Use
MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE
APPLICABILITY OF THIS PRIVACY NOTICE
ADDITIONAL INFORMATION AND ASSISTANCE
YOUTUBE API SERVICES AND DATA COLLECTION
OVERVIEW
TradeZing LLC together with its affiliates and subsidiaries (collectively, “TradeZing,” “we,” “us,” “our”) respect your privacy and is committed to protecting the personal data we hold about you. TradeZing offers a digital media platform that enables content creators to post (and, in some instances, monetize) digital content. TradeZing refers to these content creators as “Partners.” If you have questions, comments, or concerns about this Privacy Notice or our processing of personal data, please see the bottom of this Privacy Notice for information about how to contact us.
This Privacy Notice explains how TradeZing collects, uses, and discloses information about you when you visit our website or app, open an account, view Partner Content or publish content with us, purchase or view our products or services, contact our customer service team, engage with us on social media, podcasts, or otherwise interact with us. (the website, apps, products, services, and social media pages, collectively, the “Services”).
Please review the following to understand how we process and safeguard personal data about you. By using any of our Services, whether by visiting our website, app or otherwise, and/or by voluntarily providing personal data to us, you acknowledge that you have read and understand the practices contained in this Privacy Notice. This Privacy Notice may be revised from time to time, so please ensure that you check this Privacy Notice periodically to remain fully informed.
PERSONAL DATA WE COLLECT
(a) Account Information. If you wish to use our Services, such as to create or post content, comment on other people’s content or to post your own content to Partners’ content, or if you wish to receive updates or newsletters from us or from our Partners, you will be required to create a TradeZing account. When you create an account or use our Services, we ask you to provide certain personally identifiable information such as your first and last name, email address, telephone number, address, and payment card information (collectively, “Personally Identifiable Information”). We may also ask for information such as a profile picture or your social profile information. If your content is supported by advertising or paid subscriptions, we also collect your payment information to allow us to pay you in accordance with your agreement with us. We may also collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal data”). In addition, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not personal data. To the extent this data is stored or associated with personal data, it will be treated as personal data; otherwise, the data is not subject to this notice.
(b) Automatically Collected Data. When you access or use our Services, we automatically collect certain technical information, including:
(c) 3. Information Collected by Cookies sand other analytics such as Firebase, Google Analytics, Mixpanel, web beacons and AppsFlyer, pixel tags, and other similar technology.Information Obtained from Others. When you access and use our Services, we may collect information about you that we collect from other sources such as identify verification services, credit bureaus, payment processors, order processing and fulfillment services, commercial email providers, security consultants, and other service providers we engage, as well as from third parties, such as ad networks, mailing list providers, and publicly available sources. Also, if you create a log in through a third-party social media site or other third party service, we may have access to certain information from that service consistent with authorization provided through that services.
How We Use Your Personal Data
We collect and process your personal data as part of providing the Services, which include:
Who We Share Your Personal Data With
We may share personal data with the following categories of third parties:
Our service providers, including software and web developers, commercial email providers, security and other consultants, IT providers, web hosting providers, and other vendors we engage so that they may provide services to us or on our behalf;
Cookies, Web Tracking, and Advertising
We use cookies to collect information about how our users use and interact with the Services, such as what pages are visited most often, how the Services are used and function, or how users navigate the Services. We use this information to improve the Services and their content. We also use cookies to remember information that you have provided or choices you have made on the Services, such as saving your logged-in status or site preferences. This allows us to provide a more personalized and convenient browsing experience.
We may allow third party advertisers, including advertising providers and ad networks, to place and/or activate cookies, pixel tags, and/or other tracking technologies designed to enable advertising on your device and deliver it to you across the Internet. These services may collect information and data about your activities online, both on the Services and across third-party pages or platforms that participate in the ad network. This process helps us track the effectiveness of our marketing efforts and deliver advertising to you.
“Cookies” are small strings of text or computer code stored locally on your device that allow us, ad networks, and our third-party service providers, to identify your browser and/or device as you browse the Internet. Cookies can be placed, read, and/or written to by our Services, or other websites or services that recognize a particular cookie, which allows the website to “remember” or “recognize” a particular browser or device and, in some cases, store information about that browser or device. Cookies are often used in conjunction with “pixel tags” (also known as “web beacons” or “clear gifs”). Pixel tags are small images that we, our analytics providers, advertisers, and other third parties can use to interact with cookies and other tracking technologies.
For more information about cookies, please see www.allaboutcookies.org.
YOUR RIGHTS REGARDING PERSONAL DATA
You have certain rights regarding the collection and processing of personal data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Notice, or by following instructions provided in this Privacy Notice or in communications sent to you.
1. Accessing, Modifying, Rectifying, and Correcting Collected Personal Data
We strive to maintain the accuracy of any personal data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up-to-date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and notify us as soon as possible of any updates or corrections.
Depending on the laws that apply to you, you may obtain from us certain personal data in our records. If you wish to access, review, or make any changes to personal data you have provided to us through the Services, please contact us at the information provided at the end of this Privacy Notice. We reserve the right to deny access as permitted or required by applicable law.
2. Your California Privacy Rights
This California privacy rights statement (“California Notice”) supplements the TradeZing Privacy Policy. The CCPA provides consumers (California residents) with specific rights regarding their personal information. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity,, we will disclose to you:
The categories of personal information we collected about you.
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see Exercising Your Rights to Know or Delete), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Exercising Your Rights to Know or Delete
To exercise your rights to know or delete described above, please submit a request by either: ● Emailing us at [EMAIL ADDRESS].
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
You do not need to create an account with us to submit a request to know or delete. [However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.
We will only use personal information provided in the request to verify the requestor’s identity or authority to make it. For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please [contact]
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales Opt-Out and Opt-In Rights
If you are age 16 or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following Internet Web page link:
[HYPERLINKED URL with the title “Do Not Sell My Personal Information”]
Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by:
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time. []
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [EMAIL ADDRESS][
Your Nevada Privacy Rights
Nevada law permits our users who are Nevada consumers to request that their personal data not be sold (as defined under applicable Nevada law), even if their personal data is not currently being sold. Requests may be sent to [email protected], and are free of charge.
YOUR CHOICES
You have choices about certain information we collect about you, how we communicate with you, and how we process certain personal data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.
a. Communications Opt-Out. You may opt out of receiving marketing or other communications from us at any time through a given communications channel (such as email or telephone) by following the opt-out link or other unsubscribe instructions provided in any email message received, by contacting us as provided at the end of this Privacy Notice. Note that if you do business with us in the future, you may not, subject to applicable law, opt out of certain automated notifications, such as order or subscription confirmations, based on business transactions (e.g., e-commerce).
b. Location Information. If you want to limit or prevent our ability to receive location information from you, you can deny or remove the permission for certain Services to access location information or deactivate location services on your device. Please refer to your device manufacturer or operating system instructions for instructions on how to do this.
c. Cookies, Web Tracking, and Advertising. Most browsers automatically accept cookies by default, but you can adjust your device and/or browser settings to delete and/or block some or all cookies, or provide notifications when you receive a new cookie. Consult the “Help,” “Tools,” or “Preferences” menus on your browser, or the documentation for your device, for more information about how to do this. Please note, however, that blocking or deleting certain cookies may negatively affect your user experience, and you may not have access to certain features and services that make your online experience more efficient and/or enjoyable.
Analytics. If you wish to opt out of Google Analytics, you can download and install an opt-out browser add-on for certain browsers here: https://tools.google.com/dlpage/gaoptout.
Advertising. Certain devices and browsers allow you to reset your advertising identifier at any time by accessing the privacy settings on your device in order to restrict the delivery of tailored in-application advertisements. Consult your device’s documentation for more information about how to do this.
PROTECTING PERSONAL DATA
We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. Those safeguards include: (i) the encryption of personal data where we deem appropriate; (ii) taking steps to ensure personal data is backed up and remains available in the event of a security incident; and (iii) periodic testing, assessment, and evaluation of the effectiveness of our safeguards.
However, no method of safeguarding information is completely secure. While we use measures designed to protect personal data, we cannot guarantee that our safeguards will be effective or sufficient. In addition, you should be aware that Internet data transmission is not always secure, and we cannot warrant that information you transmit utilizing the Services is or will be secure.
OTHER IMPORTANT INFORMATION ABOUT PERSONAL DATA AND THE SERVICES.
MODIFICATIONS AND UPDATES TO THIS PRIVACY NOTICE
This Privacy Notice replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Notice, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Notice. We will use reasonable efforts to notify you in the event material changes are made to this] Privacy Notice, such as sending you an email. Your continued use of the Services following our posting of any revised Privacy Notice will constitute your acknowledgement of the amended Privacy Notice.
APPLICABILITY OF THIS PRIVACY NOTICE
This Privacy Notice is subject to our Terms of Use [Insert hyperlink] and any partner or affiliate agreements, as applicable, that govern your use of the Services. This Privacy Notice applies regardless of the means used to access or provide information through the Services.
This Privacy Notice does not apply to information from or about you collected by any third-party services, applications, or advertisements associated with, or websites linked from, the Services. The collection or receipt of your information by such third parties is subject to their own privacy policies, statements, and practices, and under no circumstances are we responsible or liable for any third party’s compliance therewith.
ADDITIONAL INFORMATION AND ASSISTANCE
If you have any questions or concerns about this Privacy Notice and/or how we process personal data, please email [email protected].
For more information about how users with disabilities can access this Privacy Notice in an alternative format, please email us at [email protected].
ADDITIONAL INFORMATION FOR EUROPEAN UNION USERS
If you reside in a country in the European Economic Area or in Switzerland (a “European Resident”), then information we collect from you may be subject to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the “GDPR”)), and the following additional information is provided for your benefit.
The controller of the Personally Identifiable Information collected through the Services is your employer or the other entity on whose behalf you are accessing or using our Services.
The processor of your Personally Identifiable Information is:
[email protected]
Processing Purpose | Legal Basis |
---|---|
To provide the Services | You have entered a contract with us and we need to use your Personally Identifiable Information to provide services you have requested or take steps that you request prior to providing services. |
To send you marketing communications; For security compliance; fraud prevention and safety; to prosecute or defend legal claims; to deliver advisements. | These processing activities constitute our legitimate interests. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your Personally Identifiable Information for our legitimate interests. We do not use your Personally Identifiable Information for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You have the right to object to, and seek restriction of, such processing; to exercise your rights, please email us at [email protected]. |
For compliance with law | Processing is necessary to comply with our legal obligations. |
With your consent | Processing is based on your consent. Where we rely on your consent you have the right to withdraw it anytime in the manner indicated in the Services or by contacting us at [email protected].. |
DISCLOSURES OF YOUR INFORMATION
We may also disclose your Personally Identifiable Information, (as well as Other Information, without the same restrictions that apply to your Personally Identifiable Information) to our service providers who we engage to perform certain functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, conducting audits, and performing web analytics) as well as on the service providers’ own behalf and on behalf of third parties who may be affiliated with our service providers (collectively, the “Subprocessors”). A list of our Subprocessors and a description of the services that they perform for us follows. We establish data processing agreements that govern our Subprocessors’ use of your Personal Information, but our Subprocessors use of your Personal Information may also be subject to the Processors’ own privacy policies.
Retention
We will only retain your personal information for as long as necessary to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your rights
European data protection laws give you certain rights regarding your personal information. You may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests by email [email protected] or our postal address provided above. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us or submit a complaint to the data protection regulator in your jurisdiction. You can find your data protection regulator at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
CROSS-BORDER TRANSFER
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Your personal information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you consent to the transfer of information to countries outside of your country of residence, including the United States. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
QUESTIONS AND COMPLAINTS
If you have any questions or complaints regarding our use of your personal information, please contact us at [email protected]
You also have the right to submit a complaint to your applicable Data Protection Authority.
YOUTUBE API SERVICES AND DATA COLLECTION
We use the YouTube API Services to provide videos feed on our website. By accessing and using our website, you agree to be bound by the YouTube Terms of Service available at https://www.youtube.com/t/terms. Please note that our website utilizes the YouTube API Services, and as a result, certain data may be collected and processed by YouTube as described in their Privacy Policy. For more information on how YouTube collects, uses, and protects your personal information, please refer to the Google Privacy Policy at https://policies.google.com/privacy.